IR 05000334/1993010
| ML20044H322 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 05/07/1993 |
| From: | Joseph Nick, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20044H320 | List: |
| References | |
| 50-334-93-10, 50-412-93-11, NUDOCS 9306080185 | |
| Download: ML20044H322 (8) | |
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e U.S. NUCLEAP REGULATORY COMMISSION
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REGION I
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f Report Nos.
50-334/93-10 50-412/93-11 Docket Nos.
50-334
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50-412
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Licensee:
Duquesne Licht Company One Oxford Center Pittsburgh. Pennsylvania 15279 Facility Name:
Beaver Vallev Power Station. Units 1 and 2 i
t Inspection At:
Shiopingoort. Pennsylvania Inspection Period:
April 26 - 30.1993
Inspector:
O.
\\b 4'NG J. Nick, Radiation Specialist Date'
Facilities Radiation Pro on Section, DRSS Approved by:
Mr JAs tw I'h77
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- hfalt Pasciaky 6ief Date Facilities R:fl'ation Protection Section, DRSS A_rgs Inspected: This inspection focused on the radiological controls pmgram and job coverage for outage work.
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Results: The licensee provided good health physics coverage to protect the health and safety of the radiological area workers. The mdiological controls for the steam generator work and the reactor head lift were appropriate and comprehensive. Adequate information was provided to workers for.
awareness of the mdiological conditions in their work areas. The strong ALARA pmgram was a significant contribution in lowering total dose and dose rates in some work areas. The self-assessment and surveillance programs continued to promote identification and msolution of problems in a timely manner. Within the scope of this inspection, one non-cited violation was identified
involving access control during radiographic opemtions (see Section 5.0).
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O gpogOcM0500o334 285 93052s
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DETAILS 1.0 Persons Contacted i
1.1 Licensee Personnel
- D. Spoerry, Vice President '- Nuclear Operations
- G. Thomas, Vice President - Nuclear Services
- L. Freeland, General Manager - Nuclear Operations
- T. Noonan, General Manager - Nuclear Engineering and Safety'
- R. Vento, Manager, Health Physics
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- N. Tonet, Manager, Nuclear Safety
- K. Gmda, Manager, QSU
- K. Ostrowski, Manager, Unit i Operations
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- D. Girdwood, Director, Radiological Operations Unit I
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- E. Cohen, Director, Radiological Operations Unit 2
- J. Lehda, Director, Radiological Engineering and Health
- F. Lipchick, Senior Licensing Supervisor
- A. Mizia, QSU Supervisor
- B. Sepelak, Licensing Engineer
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W. McIntire, Director, Safety and Environmental Services
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A. Klutka, Industrial Safety Engineer J. Freund, Senior Health Physics Specialist M. Helms, Senior Health Physics Specialist R. Pucci, Health Physics Specialist Various other licensee employees were contacted and interviewed during this inspection.
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1.2 NRC Personnel
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- L. Rossbach, Senior Resident Inspector
- P. Sena, Resident Inspector
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- S. Greenlee, Resident Inspector
- Denotes those present during the exit meeting 2.0 Pumose
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The purpose of this announced inspection was to assess the Beaver Valley Power Station's:
implementation of the radiological controls program during. outage conditions.
Areas reviewed included containment radiological controls, job coverage for outage work, health _
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physics training, the.ALARA program, dose assessments and assignments, quality assurance,
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and instructions to workers.
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3.0 Organization and Staffing
The nonnal health physics organization that consists of 48 senior technicians and 12 foremen was augmented with approximately 230 tempomry contractor personnel. The contmetor human resources included 138 senior health physics technicians,46 junior health physics
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technicians,25 foremen, and 22 assistants. Two station Health Physics (HP) Specialists and j
one HP Supervisor were placed in the position of HP Coordinator for each work shift and
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reported to the Director of Radiological Operations. Four to eight foremen reponed to the i
shift HP Coordinator. The foremen's plant area responsibilities included steam generators,
.j refueling activities, containment, auxiliary building, inservice inspection, and foreign object search and recovery (FOSAR). Six to eighteen technicians reported to each of the various l
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foremen to suppon the radiologicaljob covemge of work in each plant area. HP suppon functions were generally staffed for continuous outage support and included ALARA, i
radwaste, respiratory protection, and dosimetry.
The HP organization was staffed to i
adequately meet the cutage workload and no deficiencies were noted.
4.0 Contmetor HP Training j
I The licensee continued to use the Site Specific Radiation Technician Tmining Program
.l (SSRTTP) that was developed to supply site specific mdiation protection knowledge to contractor HP technicians. The SSRTTP was reviewed during a previous inspection (NRC Inspection Report Nos. 50-334/92-06; 50-412/92-03) and had not been substantially changed since that time.
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After a passing gmde was obtained on the SSRTTP exams, the technicians were given Job l
Performance Measures (JPMs). The JPMs were developed to evaluate the mastery of on-the-
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job skills. The licensee had indicated during a previous inspection (NRC Inspection Repon
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Nos. 50-334/92-06; 50-412/92-03) that the JPMs would be reviewed since they were carried l
over from the previous course. The JPMs had been reviewed prior to commencement of training for this outage and appropriate changes were made.
l According to a licensee document titled "SSRTTP Course Letter", proficiency maintenance i
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could be satisfied in three different ways. The first method allowed an individual who was returning to the licensee's site from the previous refueling outage at the same job
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i classification to review the SSRTTP material and undenake an open book exam. A JPM for
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returning technicians may be required. The second method allowed attendance in continuing
training modules throughout the year. The third method required the technician to complete
the entire SSRTTP if the technician was not present at the last refueling outage or has
changed job classification. An additional waiver was allowed for any individual used as an i
instmetor for the SSRTTP, upon approval from the Director of Radiological Operations.
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The licensee had waived the SSRTTP for nine individuals for this outage. The waiver was
documented in a shon memo from the Director of Radiological Operations, Unit I to the
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training department. The memo did not specify why the individuals were waived, or the j
basis for detennining the qualineations of these individuals. The inspector expressed concern that the detennination for the waiver was not documented for future mference.
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An inspection of a random sample of qualification and training documentation for the contractor HP technicians did not reveal any de6ciencies with the licensee's training
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requirements, l
5.0 HP Job Covemge The licensee provided health physics job coverage for radiography work performed by MQS
Inspection, Inc. on the recirculating spray heat exchangers. The work was performed in the containment building under Radiation Work Pennit (RWP) number 93-273. Work steps 8
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and 9 on this RWP require the Radiological Contmls group to post and establish boundaries,
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restrict entry to the affected area, and perfonn a thomugh search prior to source exposure
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to evacuate all unnecessary personnel.
On April 26,1993, the licensee provided health physics controls for radiography on elevation 692' in containment. The licensee posted and searched the area on elevation 692' and also -
posted and searched the area above on elevation 718'. Approximately 20 minutes after the
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radiography had begun, two workers exited the controlled area for radiography on elevation
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718'
The workers were on a very high, multiple level scaffold during the mdiography
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opemtion. Although the area was searched, the workers were not detected on the scaffold.
i An announcement was broadcast over the public address system in the area, but noise conditions prevented the announcement from being heard by the workers. The dosimetry assigned to the workers did not indicate any additional exposure from this event, and the I
licensee did not expect any additional exposure from the radiography to penetrate to this area.
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Although the workers did not receive additional radiation exposure, this event created the potential for an unplanned radiation exposure due to the loss of radiological control during radiographic operations. This is an apparent NRC Severity Level IV violation. The licensee took prompt corrective action by instructing the health physics supervision on preventative measures before the next radiography operation was conducted. The preventative measures included reducing the size of the area controlled for radiography work, requirements for a i
comprehensive search of all scaffolds or other stmetures, and documentation of all searched areas prior to commencing radiography. Because this was a licensee identified, NRC
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Severity Level IV violation for which the licensee took prompt corrective actions, this violation will not be subject to enforcement action. The licensee's efforts meet the criteria specified in Section VII.B of the Enforcement Policy (10 CFR 2, Appendix C).
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5.1 Steam Generator Work j
Before work was perfonned on steam genemtors A, B, and C during this outage, the licensee extensively planned the work and tmined personnel on a new steam generator mock-up in an adjacent warehouse.
The mock-up was constructed and used since the last NRC
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inspection. During construction of the mock-up, the licensee made an effoit to create a
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realistic model of the steam genemtor and the general work area. This included enclosures, i
shielding, protective covers, air filtmtion units, other radiological controls, and worker's
tools and equipment. Some general radiation protection training was recorded on videotape for future use.
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Before the steam generator work started, radiation dose rate surveys were conducted'using both radiation survey instruments and a group of thermoluminescent dosimeters (TLDs).
l The TLDs were arr;mged on a pole that was placed in the steam generator bowl for a period
of five to six minutes. The TLDs were pmcessed and the results were compared to the
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radiation survey instmment data to ensure a close correlation. This was an important step -
i to verify that the survey dose rates would correspond to the personnel radiation dose as
monitored by TLDs.
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Based on the radiation dose mte survey data, the health physics personnel controlled stay l
times in the area of the generators and actual steam genemtor entries. RCM Fonn 5.3, i
" Authorization for Steam Generator Platfonn Work" was used to record all current dose and
allowable dose margins. The fonn was well designed and provided important infonnation i
to control access and stay times in the area.
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Steam generator work was controlled from a d=sk outside the L:ciselv. wall through the use i
of video and audio equipment. This allowed suraillance from a lc,wer dose rate area than j
the area near the open steam generators. Temporary shielding was erected between the
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steam generators and the entrance to the steam generatm cubicles. 'A containment tent was also erected around the openings of the stean genemtors to control contamination. A i
j technician was assigned to dress and undress workers when they entered and exited the steam generator work area.
Appropriate multiple dosimetry sets were created for the different types of steam generator
entries. When an entry for a worker's entire body was planned, the worker wore dosimeters i
on the head, chest, back, upper anns, thighs, ankles, wrists, and fingers. If only the worker's head and shoulders were planned to enter the steam generator opening (manway),
I then the worker wore dosimeters on the head, chest, upper anns, wrists, and fingers. Other workers that were not allowed to enter the steam generators were monitored by dosimetry
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worn in the nonnal chest location. The dosimetry monitoring for the steam generator workers was appropriate and no weaknesses were noted.
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5.2 Other Containment Work
The inspector reviewed the reactor head lift job evolution to detennine the scope of job planning, use of engineering controls to minimize airborne radioactivity, appropriate -
personnel monitoring, respintory protection, and other radiological controls used for the protection of workers. The job had been planned and discussed by the various groups involved in the work scope. Health physics personnel detennined the engineering controls
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necessary to minimize airborne radioactivity based on historical data.
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The head lift was done on the early morning shift of April 21,1993. Based on historical
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data and recent indications from open systems, the licensee detennined that airborne concentrations would be minimal and the use of respimtors was only necessary for personnel on the lower elevations. A High Efficiency Particulate Air (HEPA) ventilation unit was
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placed in the vicinity of the reactor head stand to draw and filter air from the reactor head
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during stomge. Air sampling was perfonned during the entire evolution, but a Constant Air
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Monitor (CAM) that could give an instantaneous alarm was not used. When the inspector
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questioned the use of a CAM, the licensee responded that the direct dose contribution from t
the reactor head would interfere with the alann settira on the CAM and that the expected
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noble gas mlease would also indicate as an alarm. However, this did not preclude the
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licensee from using the CAM with shielding from the dimet dose. An alann was detected
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on the gas channel of the containment ventilation monitoring system during the initial head lift, and the licensee attributed the alann to xenon gas.
When workers attempted to leave the controlled area after the head lift, multiple personnel contaminations were detected. The licensee determined from air sample analysis that a radioactive airborne particulate had been released to the containment building sometime during the head lift operation. The release was not expected, but air samples were conducted in the event of a release. From the air sample results, the licensee also detennined the highest concentration to be 6 MPC-hours for beta and gamma emitting isotopes and 7 MPC-
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hours from alpha emitting isotopes. Additionally, approximately 80 personnel working in
the containment building were counted in the in-vivo bioassay facility, even though all personnel were below the licensee's procedural requirement for bioassay based on contamination levels. The maximum estimated internal dose assignment from the airborne radioactivity was less than 15 MPC-hours, which compares to a regulatory limit of 520 MPC-hours per calendar quaner.
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Overall. the licensee took appropriate measures to minimize airbome radioactivity and intakes by workers. The job scope was well planned and personnel were adequately monitored for external dose and intemal uptakes.
a Various other Radiation Work Pennits (RWPs) were reviewed for appropriate instructions to workers and proper mdiological controls. These RWPs included pressurizer work, steam i
genemtor inspections and sludge lancing, reactor cavity decontamination, and reactor coolant
pump work. The instructions to workers were adequate and no deficiencies were noted.
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2 6.0 ALARA Program
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As of April 26, 1993, the Beaver Valley Unit I ninth refueling outage personnel had accumulated 209 person-rem. The personnel exposure goal for all outage work was 435 person-rem. Work on the steam generators represented approximately 40% of the personnel exposure for the outage to date. This accumulated personnel dose total included a special test of an experimental steam generator tube repair perfonned by a vendor.
This experimental repair was not originally included in the outage planning and dose budgeting.
The estimated personnel dose from the steam genemtor repair and inspection activities was approximately 20 person-rem.
The highest personnel whole body total exposure to an individual for the second calendar quaner of 1993 was 975 millirem. This number is well below the regulatory limit of 3000 j
millirem for an individual for any calendar quarter. The highest recorded dose to the skin
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of the whole body for an individual for the second calendar quaner of 1993 was 1345 t
millirem, which compares to the regulatory limit of 7500 millirem per calendar quaner. The highest recorded extremity dose to any personnel for the second calendar quarter of 1993 was 1908 millirem and the regulatory limit for extremity dose is 18750 millirem per calendar quaner. Individual dose totals reported for the first calendar quaner of 1993 wen: lower than the second calendar quarter 1993 individual dose totals because the scope of work was much smaller during the first quarter.
The licensee continued to use various ALARA tools for the ninth refueling outage. These tools included; pre-outage planning meetings incorporating lessons learned from previous outages, shielding design packages, automated tools for work in high dose rate areas, use of
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closed circuit television for surveillance activities, training on mock-up systems and
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components, use of a digitizing camem to reproduce component drawings, engineering controls for ventilation and filtration of airborne mdicactivity, pre-job briefings and
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discussions, and surveillance ofjobs in progress to detennine if further ALARA techniques
could be utilized. The primary system was nm in a heated mode with a lower pH level for an extended time period during shutdown which helped to reduce the contamination levels and lower dose rates in the steam generators.
l 7.0 Other Items The licensee continued to use self-assessment and surveillance programs to identify and correct problems in a timely effort. The self assessments were perfonned by technicians and supenisors from the radiological controls depanment.
Additionally, six non-station personnel were used as Quality Assessors during the outage period. The role of the Quality Assessor was to observe work in progress for compliance with Radiation Work Pennits i
(R.WPs) and procedures. Typica ly, areas of non-compliance were brought to the attention of supervision for review and discussion. If the area of non-compliance was immediately threatening to safety, the item could be discussed with the workers. The inspector expressed
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i some concern about workers taking direction from personnel whose qualifications were not reviewed for compliance with ANSI N18.1 - 1971 (Selection and Training of Nuclear Power
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Plant Personnel) standards. The licensee assured the inspector that the Quality Assessors
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were only suggesting areas of non-compliance and that the final decision was left to the i
qualif'ied workers or supervisors. The use of the Quality Assessors was a good practice for identifying weaknesses or procedural problem areas.
Tours through other amas of the plant were conducted to observe work in radiological areas.
Other areas included the auxiliary building, the fuel handling building, and radwaste. Minor discrepancies in the posting of radiological areas were brought to the attention of management. These discrepancies were promptly corrected. All areas were locked and barricaded as required by NRC mgulations.
Housekeeping in most areas was good considering the scope of outage work in progress.
8.0 Exit Meeting A meeting was held with licensee representatives at the end of the inspection period on April 30,1993. The purpose and scope of the inspection were reviewed and the findings of the inspection were discussed.
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